WASHINGTON, DC — February 25, 2003 — The record-keeping costs to implement the country-of-origin labeling law will be substantially more than the $2 billion estimate by the U.S. Department of Agriculture (USDA), according to comments filed recently by the Food Marketing Institute (FMI).

Food retailers will require far more than the estimated 40 hours to set up a labeling system and one hour per day to maintain it, according to the comments. The typical retailer carries more than 600 beef, pork, lamb, fish, fruit, vegetable and peanut products covered by the law. “As retailers use multiple suppliers for each covered commodity, records will need to be developed and negotiated thousands of times over so that the retailer will have the necessary information for each supplier of every covered commodity,” said Hammonds.

The estimate, he said, completely omits any costs to segregate products by country throughout the supply chain; to design, print and attach the labels; to audit companies to verify that the labels are accurate; and to train employees.

Preexisting federal and state laws will provide little help in meeting the record-keeping requirements, according to Hammonds. “The Perishable Agriculture Commodities Act (PACA) does not require any sort of records relevant to the beef, pork, lamb, fresh or frozen shellfish or peanuts at all. The Tariff Act does not require any country-of-origin records for domestic products.

“The Florida country-of-origin law, which proponents view as a model, does not apply to frozen produce, muscle cuts of beef, pork, and lamb; ground beef, pork and lamb; fresh and frozen seafood — which must also be identified as ‘farm-raised’ or ‘wild-caught’ — and peanuts. The federal law requires a country of origin determination that is far more complex than that required under the Florida law.”

Copies of FMI’s comments are available at www.fmi.org/gr/comments/.